On March 12, 2019 a
Party Discovery
was filed
involving a dispute between
Ruiz, Alexander,
and
Loma Linda University Medical Center,
Nabil Koudsi, M.D.,
San Antonio Regional Hospital,
Steven Ernst, M.D.,
for Complaint for Medical Malpractice
in the District Court of San Bernardino County.
Preview
1 Gary M Schneider Esq SBN 72553
NancY Siccama Esq SBN 285800 F
suP
2 LAW OFFICES OF GARY M SCH EIDER RroR co E D
cou v URT QFC FO
12100 Wilshire Boulevard Suite 1100 SAN g R gE N
Los Angeles Califomia 90025 7111
A N N CNIt p
J
3
Telephone 310 820 5544
S N
p
4 Facsimile 310 820 6024 81010
5 Attomeys for Plaintiff
6
7
8
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
9
IN THE COUNTY OF SAN BERNARDINO
10
I1
12 ALEXANDER RUtZ CASE NO CIVDS1907976
13
Plaintiff PLAINTIFF S SEPARATE STATEMENT
1 q OF DISPUTED AND UNDISPUTED
vs MATERIAL FACTS AND SUPPORTING
15 EVIDENCE SUBMITTED IN OPPOSITION
TO MOTION FOR SUMMARY
16 SAN ANTONIO REGIONAL HOSPITAL JUDGMENT OF DEFENDANT STEVEN
LOMA LINDA UNIVERSITY MEDICAL ERNST M D
i7 CENTER STEVEN ERNST M D NABIL
KOUDSI M D and DOES 1 thraugh 1Q0 Date September22 2020
Z8 inclusive Time 1 30 p m
Dept S27
19
Filed concurrentty with Plaintiffs Points
2p Defendants and Authorities in pposition ta Motion for
Summary Judgment of Defendant Steven
21 Emst M D Declaration of Richard
Sonner M D Submitted in Oppositivn to
22 Motion for Surnmary Judgment of
Defendant Steven Emst M D and
23 Deciarafion of Gary M Schneider e
24 Trial Date March 29 2021
Complaint Filed March 12 2019
25
26
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD
27
Plaintiff hereby submifs this Separate Statement of Disputed and Undisputed
28
1
PW NTfFF8 SEPARATE STATEMENT OF DISPIlTED AND UNDISPUTED MITERW FACTS AND SUPPORTWt3 EVtIIBICE SUBMiTTED IN
OPPOSITION 70 M07 N FOR 8UMMARY JUDCiMENT OF DEFENOANT STEVEN ERNST MD
1 Material Facts and Supporting Evidence in opposition to the Mofion for Summary
2 Judgment of Defendant STEVEN ERNST M D
3
Movin Parlv s Undisputed Ma e ia Plaintiffs Resaonse and Su paorting
4
Facts and Supporting Evidence Evidence
5 1 Plaintiff ciaims the care provided to 1 Undisputed
6
him by Dr Emst while in the emergency
depa tment at San Antonio Regional
a Hospitat on October 6 7 2017 fe11 below
9 the standard of care specificaliy with regard
10 to delayed treatment of his vascular injury
11 qs a result he underwent a below the knee
12
amputat on on February 26 2418
13
Supporting Evidence Exhibit A
14 2 On Octobet 6 2017 at 8 02 p m 2 Undisputed
15 emergency medical services amved at San
16 Antonio Regional Hospital with patient
17 Alexander Ruiz DOB OZ115 2001 with a
z 8 right leg injury sustained whfle playing
l9 football He was triaged at approximatefy
20 8 t 1 p m and nursing noted they were
21 unable to palpate dorsalis pedis puise of
22 the right lower extremity with capillary refill
23 equal to three seconds
24 Supporting Evidence Fachibit B pp 16 39
25
26
27
28
2
PLAINT FFS SEPARATE STATEMENT OF DISPUTED AND UNDISPUTED MATERULL FACTS MED 9UPPORTWO EVtDENCE SUBMffTEQ IN
ERNSf M
OPP031TtON TO MOTION FOR St1MMARY JUDCiMENT OF OEFENDANT 8TEVEN D
Document Filed Date
September 08, 2020
Case Filing Date
March 12, 2019
Category
Complaint for Medical Malpractice
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Preview
1 Gary M Schneider Esq SBN 72553 NancY Siccama Esq SBN 285800 F suP 2 LAW OFFICES OF GARY M SCH EIDER RroR co E D cou v URT QFC FO 12100 Wilshire Boulevard Suite 1100 SAN g R gE N Los Angeles Califomia 90025 7111 A N N CNIt p J 3 Telephone 310 820 5544 S N p 4 Facsimile 310 820 6024 81010 5 Attomeys for Plaintiff 6 7 8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 9 IN THE COUNTY OF SAN BERNARDINO 10 I1 12 ALEXANDER RUtZ CASE NO CIVDS1907976 13 Plaintiff PLAINTIFF S SEPARATE STATEMENT 1 q OF DISPUTED AND UNDISPUTED vs MATERIAL FACTS AND SUPPORTING 15 EVIDENCE SUBMITTED IN OPPOSITION TO MOTION FOR SUMMARY 16 SAN ANTONIO REGIONAL HOSPITAL JUDGMENT OF DEFENDANT STEVEN LOMA LINDA UNIVERSITY MEDICAL ERNST M D i7 CENTER STEVEN ERNST M D NABIL KOUDSI M D and DOES 1 thraugh 1Q0 Date September22 2020 Z8 inclusive Time 1 30 p m Dept S27 19 Filed concurrentty with Plaintiffs Points 2p Defendants and Authorities in pposition ta Motion for Summary Judgment of Defendant Steven 21 Emst M D Declaration of Richard Sonner M D Submitted in Oppositivn to 22 Motion for Surnmary Judgment of Defendant Steven Emst M D and 23 Deciarafion of Gary M Schneider e 24 Trial Date March 29 2021 Complaint Filed March 12 2019 25 26 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD 27 Plaintiff hereby submifs this Separate Statement of Disputed and Undisputed 28 1 PW NTfFF8 SEPARATE STATEMENT OF DISPIlTED AND UNDISPUTED MITERW FACTS AND SUPPORTWt3 EVtIIBICE SUBMiTTED IN OPPOSITION 70 M07 N FOR 8UMMARY JUDCiMENT OF DEFENOANT STEVEN ERNST MD 1 Material Facts and Supporting Evidence in opposition to the Mofion for Summary 2 Judgment of Defendant STEVEN ERNST M D 3 Movin Parlv s Undisputed Ma e ia Plaintiffs Resaonse and Su paorting 4 Facts and Supporting Evidence Evidence 5 1 Plaintiff ciaims the care provided to 1 Undisputed 6 him by Dr Emst while in the emergency depa tment at San Antonio Regional a Hospitat on October 6 7 2017 fe11 below 9 the standard of care specificaliy with regard 10 to delayed treatment of his vascular injury 11 qs a result he underwent a below the knee 12 amputat on on February 26 2418 13 Supporting Evidence Exhibit A 14 2 On Octobet 6 2017 at 8 02 p m 2 Undisputed 15 emergency medical services amved at San 16 Antonio Regional Hospital with patient 17 Alexander Ruiz DOB OZ115 2001 with a z 8 right leg injury sustained whfle playing l9 football He was triaged at approximatefy 20 8 t 1 p m and nursing noted they were 21 unable to palpate dorsalis pedis puise of 22 the right lower extremity with capillary refill 23 equal to three seconds 24 Supporting Evidence Fachibit B pp 16 39 25 26 27 28 2 PLAINT FFS SEPARATE STATEMENT OF DISPUTED AND UNDISPUTED MATERULL FACTS MED 9UPPORTWO EVtDENCE SUBMffTEQ IN ERNSf M OPP031TtON TO MOTION FOR St1MMARY JUDCiMENT OF OEFENDANT 8TEVEN D